SYNTHES MATRIX SYSTEM

K092929 · Synthes (Usa) · NKB · Dec 29, 2009 · Orthopedic

Device Facts

• Record ID: K092929
• Device Name: SYNTHES MATRIX SYSTEM
• Applicant: Synthes (Usa)
• Product Code: NKB · Orthopedic
• Decision Date: Dec 29, 2009
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic, Pediatric

Intended Use

The Synthes USS (including Matrix, USS Side-Opening, USS Dual-Opening, USS Small Stature (which includes small stature and pediatric patients), USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix) are non-cervical spinal fixation devices intended for use as posterior pedicle screw fixation systems (T1-S2/ilium), a posterior hook fixation system (T1-L5), or as an anterolateral fixation system (T8-L5). Pedicle screw fixation is limited to skeletally mature patients with the exception of the Small Stature USS. These devices are indicated as an adjunct to fusion for all of the following indications regardless of the intended use: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), tumor, stenosis, and failed previous fusion (pseudoarthrosis). When treating patients with Degenerative Disc Disease (DDD), transverse bars are not cleared for use as part of the posterior pedicle screw construct. When used with the 3.5/6.0-mm parallel connectors, the Synthes USS (including USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix) can be linked to the CerviFix 3.5 mm Systems (including CerviFix, Axon, and Synapse). In addition, when used with 3.5/5.0 mm parallel connectors, the Synthes Small Stature USS can be linked to the CerviFix 3.5 mm Systems (including CerviFix, Axon, and Synapse). When used with the 5.0/6.0mm parallel connectors, the Synthes Small Stature USS can be linked to the Synthes USS (including USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix). In addition, Synthes USS (including USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix) can be interchanged with all USS 6.0 mm rods and transconnectors.

Device Story

Synthes Matrix System is a non-cervical spinal fixation system; includes pedicle bone screws, polyaxial/monoaxial pedicle screws, polyaxial/reduction heads, locking caps, transconnectors, rods, and hooks. Used as posterior pedicle screw fixation (T1-S2/ilium), posterior hook fixation (T1-L5), or anterolateral fixation (T8-L5). Designed as an adjunct to spinal fusion. Operated by surgeons in clinical settings. Implants are manufactured from titanium, titanium alloy, cobalt-chromium-molybdenum alloy, or nitinol. System allows for linkage to CerviFix 3.5 mm systems via parallel connectors and interchangeability with existing USS 6.0 mm rods and transconnectors. Provides mechanical stabilization of the spine to facilitate fusion.

Clinical Evidence

No clinical data was required or provided for this device; substantial equivalence was demonstrated through bench testing.

Technological Characteristics

Implants manufactured from titanium, titanium alloy, cobalt-chromium-molybdenum alloy, or nitinol. System includes pedicle screws, hooks, rods, and connectors. Modular design allows for linkage to CerviFix systems and interchangeability with USS 6.0 mm components. Mechanical fixation device.

Indications for Use

Indicated for skeletally mature patients (except Small Stature USS) requiring spinal fusion for degenerative disc disease, spondylolisthesis, trauma (fracture/dislocation), spinal deformities (scoliosis, kyphosis, lordosis, Scheuermann's Disease), tumor, stenosis, or failed previous fusion.

Regulatory Classification

Identification

(1) Rigid pedicle screw systems are comprised of multiple components, made from a variety of materials that allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Such a spinal implant assembly consists of a combination of screws, longitudinal members (e.g., plates, rods including dual diameter rods, plate/rod combinations), transverse or cross connectors, and interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors).(2) Semi-rigid systems are defined as systems that contain one or more of the following features (including but not limited to): Non-uniform longitudinal elements, or features that allow more motion or flexibility compared to rigid systems.

Special Controls

*Classification.* (1) Class II (special controls), when intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). These pedicle screw spinal systems must comply with the following special controls:(i) Compliance with material standards; (ii) Compliance with mechanical testing standards; (iii) Compliance with biocompatibility standards; and (iv) Labeling that contains these two statements in addition to other appropriate labeling information: “Warning: The safety and effectiveness of pedicle screw spinal systems have been established only for spinal conditions with significant mechanical instability or deformity requiring fusion with instrumentation. These conditions are significant mechanical instability or deformity of the thoracic, lumbar, and sacral spine secondary to severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra, degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis). The safety and effectiveness of these devices for any other conditions are unknown.” “Precaution: The implantation of pedicle screw spinal systems should be performed only by experienced spinal surgeons with specific training in the use of this pedicle screw spinal system because this is a technically demanding procedure presenting a risk of serious injury to the patient.” (2) Class II (special controls), when a rigid pedicle screw system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion in the treatment of degenerative disc disease and spondylolisthesis other than either severe spondylolisthesis (grades 3 and 4) at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment. These pedicle screw systems must comply with the following special controls: (i) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use. (ii) Non-clinical performance testing must demonstrate the mechanical function and durability of the implant. (iii) Device components must be demonstrated to be biocompatible. (iv) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments. (v) Labeling must include the following: (A) A clear description of the technological features of the device including identification of device materials and the principles of device operation; (B) Intended use and indications for use, including levels of fixation; (C) Identification of magnetic resonance (MR) compatibility status; (D) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user; and (E) Detailed instructions of each surgical step, including device removal. (3) Class II (special controls), when a semi-rigid system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion for any indication. In addition to complying with the special controls in paragraphs (b)(2)(i) through (v) of this section, these pedicle screw systems must comply with the following special controls: (i) Demonstration that clinical performance characteristics of the device support the intended use of the product, including assessment of fusion compared to a clinically acceptable fusion rate. (ii) Semi-rigid systems marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with the special controls in paragraphs (b)(2)(i) through (v) and paragraph (b)(3)(i) of this section.

Predicate Devices

• Synthes' existing posterior thoracolumbar spine systems

Reference Devices

• CerviFix 3.5 mm Systems (including CerviFix, Axon, and Synapse)

Submission Summary (Full Text)

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## 6 510(k) Summary

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| 510(k) Summary | |
|-----------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Name of Firm: | Synthes Spine<br>1302 Wrights Lane East<br>West Chester, PA 19380 |
| 510(k) Contact: | Susan Lewandowski<br>Manager, Spine Regulatory Affairs<br>Telephone: [phone]<br>Facsimile: 610-719-5102<br>Email: [e-mail] |
| Date Prepared: | September 21, 2009 |
| Trade Name: | Synthes Matrix System |
| Classification: | 21 CFR 888.3070 - Pedicle screw spinal system<br>Class III<br>Orthopaedic and Rehabilitation Devices Panel<br>Product Code: NKB, MNH, MNI, KWQ, KWP |
| Predicates: | The Synthes Matrix System is substantially equivalent to similar,<br>previously cleared pedicle screw spinal systems. |
| Device<br>Description: | The Synthes Matrix System is an addition to Synthes' existing<br>posterior thoracolumbar spine systems. The Matrix System consist<br>of a family non-cervical spinal fixation devices intended for use as a<br>posterior pedicle screw fixation system (T1-S2), posterior hook<br>fixation system (T1-L5) or anterolateral fixation system (T8-L5). The<br>implants include pedicle bone screws, polyaxial pedicle screws,<br>monoaxial pedicle screws, polyaxial heads, reduction screws,<br>reduction heads, locking caps, transconnectors, rods and hooks.<br>The implants are primarily manufactured from titanium, titanium<br>alloy, cobalt-chromium-molybdenum alloy or nitinol, similar to the<br>predicates. |
| Intended Use/<br>Indications for<br>Use: | The Synthes USS (including Matrix, USS Side-Opening, USS Dual-<br>Opening, USS Small Stature (which includes small stature and<br>pediatric patients), USS VAS variable axis components, USS<br>Fracture, Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial,<br>USS Polyaxial, USS Iliosacral, and ClampFix) are non-cervical<br>spinal fixation devices intended for use as posterior pedicle screw<br>fixation systems (T1-S2/ilium), a posterior hook fixation system (T1-<br>L5), or as an anterolateral fixation system (T8-L5). Pedicle screw<br>fixation is limited to skeletally mature patients with the exception of |
| <b>510(k) Summary</b> | |
| | the Small Stature USS. These devices are indicated as an adjunct<br>to fusion for all of the following indications regardless of the<br>intended use: degenerative disc disease (defined as discogenic<br>back pain with degeneration of the disc confirmed by history and<br>radiographic studies), spondylolisthesis, trauma (i.e., fracture or<br>dislocation), deformities or curvatures (i.e., scoliosis, kyphosis,<br>and/or lordosis, Scheuermann's Disease), tumor, stenosis, and<br>failed previous fusion (pseudoarthrosis). |
| | When treating patients with Degenerative Disc Disease (DDD),<br>transverse bars are not cleared for use as part of the posterior<br>pedicle screw construct. |
| | When used with the 3.5/6.0-mm parallel connectors, the Synthes<br>USS (including USS Side-Opening, USS Dual-Opening, USS VAS<br>variable axis components, USS Fracture, Click'X, Click'X<br>Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS<br>Iliosacral, and ClampFix) can be linked to the CerviFix 3.5 mm<br>Systems (including CerviFix, Axon, and Synapse). In addition,<br>when used with 3.5/5.0 mm parallel connectors, the Synthes Small<br>Stature USS can be linked to the CerviFix 3.5 mm Systems<br>(including CerviFix, Axon, and Synapse). When used with the<br>5.0/6.0mm parallel connectors, the Synthes Small Stature USS can<br>be linked to the Synthes USS (including USS Side-Opening, USS<br>Dual-Opening, USS VAS variable axis components, USS Fracture,<br>Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS<br>Polyaxial, USS Iliosacral, and ClampFix). |
| | In addition, Synthes USS (including USS Side-Opening, USS Dual-<br>Opening, USS VAS variable axis components, USS Fracture,<br>Click'X, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS<br>Polyaxial, USS Iliosacral, and ClampFix) can be interchanged with<br>all USS 6.0 mm rods and transconnectors. |
| Comparison of<br>the device to<br>predicate<br>device(s): | The Synthes Matrix System is a result of design modifications to the<br>predicate devices. It is substantially equivalent to the predicates in<br>design, function, material and intended use. |
| Performance<br>Date<br>(Non-Clinical<br>and/or Clinical): | Non-Clinical Performance and Conclusions:<br>Bench testing results demonstrate that the Synthes Matrix System<br>is substantially equivalent to the predicate devices.<br>Clinical Performance and Conclusions:<br>Clinical data and conclusions were not needed for this device. |

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## @ SYNTHES® SYNTHES® SYNTHES® Spine

**Spine**

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Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird with outstretched wings, rendered in a simple, abstract design.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

Synthes USA % Ms. Susan Lewandowski Manager, Spine Regulatory Affairs 1302 Wrights Lane East West Chester, Pennsylvania 19380

Re: K092929

Trade/Device Name: Synthes Matrix System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWO, KWP Dated: December 10, 2009 Received: December 14, 2009

Dear Ms. Lewandowski:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

DEC 2 9 2009

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Page 2 - Ms. Susan Lewandowski

forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Daniel Keane

Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## @ SVNTHES®

Spine

## 5 Indications for Use Statement

510(k) Number: Device Name: Synthes Matrix System

Indications for Use:

The Synthes USS (including Matrix, USS Side-Opening, USS Dual-Opening, USS Small Stature (which includes small stature and pediatric patients), USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix) are noncervical spinal fixation devices intended for use as posterior pedicle screw fixation systems (T1-S2/ilium), a posterior hook fixation system (T1-L5), or as an anterolateral fixation system (T8-L5). Pedicle screw fixation is limited to skeletally mature patients with the exception of the Small Stature USS. These devices are indicated as an adjunct to fusion for all of the following indications regardless of the intended use: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), tumor, stenosís, and failed previous fusion (pseudoarthrosis).

When treating patients with Degenerative Disc Disease (DDD), transverse bars are not cleared for use as part of the posterior pedicle screw construct.

When used with the 3.5/6.0-mm parallel connectors, the Synthes USS (including USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix) can be linked to the CerviFix 3.5 mm Systems (including CerviFix, Axon, and Synapse). In addition, when used with 3.5/5.0 mm parallel connectors, the Synthes Small Stature USS can be linked to the CerviFix 3.5 mm Systems (including CerviFix, Axon, and Synapse). When used with the 5.0/6.0mm parallel connectors, the Synthes Small Stature USS can be linked to the Synthes USS (including USS Side-Opening, USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, and ClampFix).

In addition, Syrthes USS (including USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X Monoaxial, Pangea, Pangea Monoaxial, USS Polyaxial, USS lliosacral, and ClampFix) can be interchanged with all USS 6.0 mm rods and transconnectors.

Prescription Use X (21 CFR 801 Subpart D) AND / OR

Over-the-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

signature

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

KO92929 510(k) Number_